In Re Zdb, 238 Or. App. 377

In a juvenile delinquency case, Z.D.B. admitted to one of two harassment counts arising from a group assault on Noble.
Noble sustained serious facial injuries; the record shows Z.D.B. kicked Noble in the ribs and the group attacked him.
The juvenile court ordered restitution of $18,442.87 for Noble’s medical expenses and related losses, despite Z.D.B. admitting only to kicking Noble in the ribs and not to causing the injuries.
The State argued restitution was appropriate because the injuries would not have occurred but for Z.D.B.’s conduct and to advance rehabilitation.
Z.D.B. challenged the restitution order, contending the court lacked authority without a direct admission tying him to the injuries.
On de novo review, the court affirmed restitution, relying on Dickerson and the broad statutory aims to promote restitution, and found a causal link between Z.D.B.’s conduct and the injuries.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does restitution require a causal link to injuries?	Z.D.B. relies on prior cases requiring a direct causation.	State contends causation or broad discretion supports restitution.	Yes; restitution may be ordered if but-for the youth's conduct the victim would not have been injured.

State ex rel. Juv. Dept. v. Dickerson, 100 Or.App. 95 (1990) (restitution requires causal relation between acts and damages)
State ex rel. Juv. Dept. v. Hal, 168 Or.App. 76 (2000) (accepts lack of causal link concession; discusses restitution scope)
State v. Sigman, 141 Or.App. 479 (1996) (restitution under criminal statute requires causation to damages from criminal activity)
State v. Gaines, 346 Or. 160 (2009) (statutory interpretation guiding restitution scope)
PGE v. Bureau of Labor and Industries, 317 Or. 606 (1993) (principles of statutory interpretation for Oregon law)
State v. Blair, 348 Or. 72 (2010) (context for amendments to restitution statute)
State v. McDonnell, 343 Or. 557 (2007) (prior construction guiding current restitution interpretation)